2021 – Edition 5 – June 4

Table of Contents

Note: The order of material varies in hotline emails, but is always presented the same on this landing page. Readers scrolling through content on or printing this page will find it organized consistent with the table of contents.

Taking Lead
Anti-Viral Measures
ARSA Works
Legal Brief
ARSA on the Hill
Training
Membership
Resources
Industry Calendar

Taking Lead

Getting Audited

By Brett Levanto, Vice President of Operations

In May, the U.S. Government Accountability Office released an assessment of the FAA’s ability to keep its workforce abreast of advancing technology. At the very highest level, the GAO got to the right point: The FAA must “…provide measurable data showing how many employees have the skills needed and where gaps exist.”

Here’s the entire 34-page report captured in two quotes:

FAA’s agency-wide workforce-planning efforts are critically important because the aviation industry today is undergoing significant changes that will affect its operating environment and workforce needs in the future.

Recognizing that additional skill gap information is needed…[the FAA] will complete additional skill gap assessments, but not until [improving] coordination on workforce planning. According to officials, a critical first step is to build up its agency-wide capacity for conducting workforce planning and to establish a mechanism to coordinate with offices on agency-wide workforce-planning activities, including future skill-gap assessments and actions for acquiring critical skills.

As ARSA told the report team last July, the agency’s personnel management practices have not kept pace with the need for its people to be less “inspectors” and more “auditors.” An auditor is a critical thinker, understanding and analyzing data produced from verifiable and validated sources…not just performing technical reviews. The FAA hires and trains for “inspecting” rather than analyzing.

FAA training is based upon “guidance” rather than a historical review and analysis of the plain language of the regulations. The “auditing shift” cannot be achieved without training to fill the gap between the technical workforce and its expectations and the legal and regulatory reality. Focus on the rules and how to ascertain the safety intent of those mandates will ensure development of data analysis (i.e., “critical thinking”) skills.

The GAO report reads as if the FAA’s “agency-wide workforce planning activities” have the situation under control “because FAA is a large and dynamic agency, the process of completing agency-wide skill gap assessments will require better coordination with individual FAA offices.” ARSA submits that this could not be further from the truth; the “stovepipe” approach does not create a dynamic, flexible workforce. It creates a “line of business” specific knowledge base that will not create the knowledge or training necessary to meet advancements in technology.

ARSA and its members can’t wait for the government to improve itself. Instead, the industry must ensure its workforce is capable of and can demand critical thinking.

To do so, the industry and the agency must build knowledge and skill standards that provide the tools for current and future workforce and technological needs. Start with the rules and the history of those requirements and the technologies that support the industry. From that base, individuals can be assessed for ability to accomplish assigned tasks within their duties, responsibilities and authorities. Gap assessments can ensure training requirements are identified and learning opportunities are made available. Focusing only on the knowledge and skills within a “department” (line of business) merely ensures that fiefdoms get created and communication is difficult.

While getting audited doesn’t sound pleasant, working with GAO researchers and analysts helps ensure congressional representatives and FAA are provided with reasonable recommendations that will improve the ability to accommodate new technologies.

To download a copy of the report and for more information from the GAO, click here.

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Anti-Viral Measures

U.S. DOT Webinar – New Aviation Jobs Program

To keep tabs on all of ARSA’s work related to the pandemic, visit arsa.org/anti-viral-measures.

The U.S. Department of Transportation hosted an introductory webinar on May 26 to overview the AMJP program and address basic questions submitted by participants.

DOT is working quickly to develop a single-round, expedited application process, to identify all eligible requests before beginning the award process.

• To access the webinar, view the stream on YouTube at www.youtube.com/embed/3JwsK9PGKhM.
• To learn more about the AMJP program, please visit www.transportation.gov/AMJP.
• To submit questions about the program, please send an email message to AMJP@dot.gov.

Click the logo to go to the PSP2 information page.

For more information from ARSA on pandemic relief policies in the United States, visit arsa.org/covid19-relief.

EASA Ramp-Up Safety Week

To keep tabs on all of ARSA’s work related to the pandemic, visit arsa.org/anti-viral-measures.

As part of its support for industry “ramp up” of operations post pandemic, EASA will host a Safety Week from June 21-24. The agency will facilitate a series of online events for the public to discuss safety issues with aviation authorities. After a general discussion, each session will focus on particular segments of the aviation community:

• ATM/ANS Providers
• Aerodrome Operators
• Training Organisations
• Air Operators
• Maintenance Organisations

Each session is limited to 1,000 registrants with initial priority given to EASA member state organizations operating in the relevant domain of the session. Beginning the week of June 14, available slots will be filled on a first come, first served basis. Session recordings will be available on the Safety Week event page within 24 hours of completion.

For more information, click here to visit the Safety Week event page.

Click the image to see the schedule.

EM.TEC Meeting Covers Brexit, Bilaterals and Pandemic Recovery

To keep tabs on all of ARSA’s work related to the pandemic, visit arsa.org/anti-viral-measures.

On May 4, ARSA Managing Director and General Counsel Marshall Filler represented the association at a remote meeting of the EASA Engineering & Maintenance Technical Committee (EM.TEC).

EASA managers briefed the committee on the current status of the European agency’s relationship with the UK CAA. Although Brexit is now a done deal (meaning the UK is like any other foreign country to EASA), the agencies have been working to determine the scope of their future aviation safety relationship.

The good news, according to EASA staff, is the two agencies will soon sign Technical Implementation Procedures (TIP) covering airworthiness issues. The bad news is that no other agreement (e.g., maintenance, simulators and flight training devices) is being discussed at this time because the issue of future cooperation in aviation and other industries is in the hands of the EU and UK politicians. EASA is waiting to see whether it will be allowed to negotiate further agreements with the UK CAA.

The EM.TEC discussed the use of prototype parts installed on an aircraft during the course of a certification project, typically an STC. EASA has indicated its current rules do not allow an aircraft to be approved for release to service with parts documented with a prototype EASA Form 1, even if the installer has determined the design data referenced in block 12 has been approved by virtue of the issuance of an EASA STC.

Unlike the FAA, EASA requires the production organization approval holder to reissue the prototype Form 1 as New for all such parts installed on the aircraft, causing delays in releasing the aircraft to service. EASA has indicated that a rulemaking would be required to change this policy and while industry does not agree with the agency’s position, that is where things stand pending further discussions. (Note: EASA has indicated verbally that it will accept prototype 8130-3s issued by U.S. suppliers to an EU design approval holder to accommodate the differences in the two regulatory systems. However, this policy is not in writing.)

Among the other issues discussed by the EM.TEC was the safety challenges associated with the post-pandemic increase in air operations, such as returning aircraft from short, medium or long-term storage. The committee also discussed policy adjustments needed to allow more flexibility for working away from a maintenance provider’s fixed location (i.e., mobile maintenance). As with prototype parts documentation, EASA’s “working away” rules are more proscriptive than the FAA’s, which allow such work to be performed on a recurring (but not continuous) basis in accordance with the repair station’s manual procedures.

The committee continued its consideration of the need to standardize policy to assure a level playing field for how component certifying staff are qualified. EASA has left this decision to its individual civil aviation authorities. Some EU countries require a separate license while others have opted to allow the maintenance organization to develop its own standards. The EM.TEC has recommended that EASA authorize all EU maintenance organizations, regardless of their location, to choose between the local’s authority’s licensing requirements for component certifying staff or its own internal qualification processes, thus leveling the playing field within the EU.

Finally, the committee was briefed on the status of MAG change 8, which recently entered into force. The most prominent aspect of the new revision involves the elimination of the country list in the bilateral aviation safety agreement between the U.S. and EU. This means that all EU countries will be treated the same for purposes of the TIP and MAG.

The next meeting of the EM.TEC will likely be held in December 2021. Most Committee members are looking forward to a resumption of in-person meetings. However, that remains to be decided based on whether the pandemic abates sufficiently to justify it. Even if the next meeting is held in-person, ARSA would support a hybrid option similar to what it is planning for future Annual Conferences.

To learn more about ARSA’s representation of the international maintenance industry, click here or contact the association.

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ARSA Works

AMT Day 2021 – Celebrating Charlie

Charles Taylor

Charles Taylor, the Wright Brothers’ mechanic and father of aviation maintenance, was born on May 24, 1868. Now – 153 years later – we celebrate him with every safe arrival and continued commitment to good work (regardless of the state of the world).

In 2008, a congressional resolution dedicated the date in honor of Taylor, establishing National Aviation Maintenance Technician Day. While the “holiday” doesn’t get anyone out of work (there are no days off from aviation safety), it’s important to celebrate the commitment, integrity and skill of every aircraft mechanic and all those who support them – this is Taylor’s legacy and our shared responsibility.

Hopefully all ARSA members recognized May 24, 2021. Those that did should share with ARSA (contact Brett Levanto at brett.levanto@arsa.org). The association often highlights member celebrations via its various communications and is always looking for great examples.

No matter how you celebrate AMT Day, it’s a small bit of well-deserved recognition. Thank you for your hard work, dedication and support.

The world can’t fly without you.

MRO Network Podcast: ARSA’s Levanto Talks Celebrating AMTs Every Day

May 24, 2019

Keep Talking at FAA Workforce Roundtable

On May 19, the FAA hosted an online Aerospace Workforce Roundtable headlined by Administrator Steve Dickson and Deputy Administrator Brad Mimms.

Dickson opened by describing the agency’s increased focus on industry career development since hosting its inaugural Aviation Workforce Symposium in 2018 (see “Hard Questions at FAA Workforce Event” below). After the administrator’s introduction, Mimms reinforced the Biden administration’s commitment to technical skills development and started off a series of briefings from various functional offices.

Those updates included—

• Ongoing expansion of the FAA Aviation & Space Education Office.
• Reinvention of the Airport Design Challenge.
• Ongoing review of workforce grant program applications.
• Establishment and progress of the Youth Access to American Jobs in Aviation Task Force and the Women in Aviation Advisory Board.
• Revision of 14 CFR part 147 and the related development of Airman Certification Standards.

Grant Program Plans

Responding to an ARSA question, participants confirmed the FAA’s 2021 plan to disburse all currently appropriated funds for aviation workforce grant programs. The agency is reviewing applications to be funded with money appropriated as part of the 2020 budget, so a second round of awards will likely be made later in the year to disburse 2021 funds.

Senior Advisor Kate Lang noted the popularity of the technician program, explaining the next solicitation will be made based on lessons learned during review of proposals received so far; requests for the initial round of funding far exceeded the resources that can be made available. The association encourages members who have already submitted to be prepared to make additional requests if no grant is received in the first round – and those who have not to get ready to do so when a new Notice of Funding Opportunity is issued.

Key Takeaway…Keep Talking

The roundtable displayed a flurry of FAA activity and reinforced the government’s interest in learning from industry and the public. In addition to enthusiastic reviews of new social media and digital communications efforts, multiple roundtable participants referenced data points or lessons learned from stakeholders and working groups. ARSA Vice President of Operations Brett Levanto, who represents repair stations on the Youth Task Force, recognized multiple references to analysis performed by his subcommittee.

“I jumped out of my seat,” Levanto said, explaining his excitement hearing a reference to work done by his fellow Task Force members. “We’d learned some really important lessons about how and when to engage students and other future aviation professionals and hearing them repeated back by FAA personnel with whom I’ve never even dealt directly was powerful. The agency is listening and its people are sharing…that just makes it even more important that we in the industry keep on talking.”

To watch a recording of the discussion, click here or view the embedded video below.

GAO Critiques FAA Workforce Planning

Click the report cover to go to the GAO webpage.

On May 13, the U.S. Government Accountability Office (GAO) released an assessment of FAA workforce planning.

The report was required by the FAA Reauthorization Act of 2018. The law tasked the GAO to review several matters, including FAA identification of critical skills needed to keep pace with new technologies. The analysis found the agency must improve how it adjusts standards for its personnel against advancing technology.

“FAA’s agency-wide workforce-planning efforts are critically important because the aviation industry today is undergoing significant changes that will affect its operating environment and workforce needs in the future,” the report said. “Mission-critical occupations that [agency] officials said are particularly important today and may be even more so in the future are aviation safety inspectors, air-traffic-controller specialists, airway transportation-system specialists, professional engineers, system inspectors, and engineering and electronic technicians.”

The GAO reviewed and critiqued the FAA’s ongoing workforce planning efforts by assessing management and employee involvement as well as the breadth of potential skills and technology areas considered. In doing so, the GAO discovered many of the needed skills identified by the FAA Office of Human Resources Management were consistent with those described by industry stakeholders (including ARSA), but the scope of the agency’s inquiry needed expansion.

“Recognizing that additional skill gap information is needed…[the FAA] will complete additional skill gap assessments, but not until [improving] coordination on workforce planning. According to officials, a critical first step is to build up its agency-wide capacity for conducting workforce planning and to establish a mechanism to coordinate with offices on agency-wide workforce-planning activities, including future skill-gap assessments and actions for acquiring critical skills,” the report concluded.

ARSA was engaged by the GAO in July 2020 to discuss FAA workforce needs. The association illustrated how inspector knowledge and capacity for critical thinking directly impacts certificate holders. While certain specific skill areas were discussed, ARSA’s team provided guidance on how FAA personnel can proactively engage industry to allow for continued learning and process improvement regardless of technology or skill-specific needs (which will always change).

ARSA members should stay tuned for the next edition of the hotline for its analysis of the GAO’s findings and some information for repair stations looking to help the FAA keep up with the times.

To download a copy of the report and for more information from the GAO, click here.

Final Documents/Your Two Cents

This list includes Federal Register publications, such as final rules, Advisory Circulars and policy statements, as well as proposed rules and policies of interest to ARSA members.

To view the list, click here.

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Legal Brief

Editor’s note: This material is provided as a service to association members for educational and informational purposes only. It does not constitute legal or professional advice and is not privileged or confidential.

An Ounce of Prevention…

By Christian A. Klein, Executive Vice President

On May 5, a former legal analyst in the FAA’s Office of Chief Counsel’s Enforcement Division was sentenced to 36 months’ probation after pleading guilty to one count of disclosure of confidential information. The case got us thinking about the legal protections in place for the data that ARSA members provide to the FAA and the need to be proactive in protecting that information.

As part of the plea deal, Brian Booth admitted sending letters to several embassies along with a handwritten list of names and addresses of 25 individuals whose U.S. pilot or maintenance certificates had been revoked. The letters demanded $27.7 million and provided payment instructions. The letter addressed to the director of Germany’s Federal Intelligence Service stated in part that:

I am an employee of the Federal Aviation Administration in Washington DC…The FAA and the Department of Homeland Security has been tracking a few suspicious people in the last three years … These people are consider [sic] terrorists…The problem right now is that the United States government is not doing a thing about this. If the United States won’t do a thing about it, then I will! I have compiled a list of twenty five individuals and companies that are committing terrorist activities against your country! They work for the aviation industry. They are pilots and mechanics who do not go through security checks at airports…I have enclosed the list and the last page of information to pay me! I am selling this information. I am committing Treason and Espionage! I expect to be paid and to seek asylum to your country, no questions asked! The last page gives instructions on how to contact me and payment information.”

The law Booth violated, 18 U.S.C. 1905 (known as the Trade Secrets Act), was first enacted in the 1940s to prevent the release of confidential information provided to the federal government. The statute applies to officers and employees of the United States or “any department or agency thereof”, as well as to other persons acting on behalf of the Federal Housing Finance Agency, on behalf of the Department of Justice in antitrust enforcement matters and private sector employees assigned to an agency.

The Act prohibits publishing, divulging, disclosing or making known in any manner or to any extent not authorized by law, any information obtained by the person “in the course of their employment or official duties…which…concerns or relates to the trade secrets, processes, operations, style of work, or apparatus, or to the identity, confidential statistical data, amount or source of any income, profits, losses, or expenditures of any person, firm, partnership, corporation, or association.”

In other words, in evaluating a potential violation of 18 U.S.C. 1905, the government must ask and answer properly the following questions:

• Is the person a covered federal employee or agent?
• Was information published, divulged, disclosed, or made known?
• Was the release authorized by law?
• Was the information obtained by the releaser in their official capacity (i.e., in the course of their employment or official duties or by examining a return, report or record filed with the agency)?
• Was the information of the type protected by the statute?

The Booth case should serve as warning. Federal employees must be extremely cautious about how information that comes into the government’s possession is handled. Arguably, Booth got off light; convictions are punishable by up to a year in prison, a fine of $100,000, mandatory restitution and removal from employment.

The warning for submitters of information is that a request for confidential treatment must be made when the information or data is provided. The information should be clearly marked as confidential (e.g., with the words “Proprietary Information”, “Proprietary Commercial Information”, “Trade Secret”, “Confidential Treatment Requested”). If it’s impractical to mark the information, a cover sheet identifying the information as confidential must be used.

Marking data submitted to the government as confidential helps protect it not just from release under the federal criminal statutes, but also from Freedom of Information (FOIA) requests. FOIA Exception 4 permits agencies to withhold from release, “trade secrets and commercial financial information obtained from a person [the is] privileged and confidential.”

The Department of Justice’s (DOJ) “Step-by-Step Guide for Determining if Commercial or Financial Information Obtained from a Person is Confidential Under Exemption 4 of the FOIA” establishes a two-part test. The first is whether the submitter customarily keeps the information private or closely held. If the information is closely held, the second question is whether the agency provided an express or implied assurance of confidentiality when the information was shared with the government.

Even if the second test is not satisfied, the data may still be considered confidential if there were no express or implied indications at the time the information was submitted that the government would publicly disclose the information. Assuming there were no such implications (i.e., “the government has effectively been silent – it hasn’t indicated the information would be protected or disclosed”), a submitter’s practice of keeping the information private will be sufficient to warrant confidential status.

In other words, when submitting data to the FAA, take steps to protect the data from release. Establishing and following policies and procedures to protest trade secrets and confidential business information and marking the data as confidential will be important in determining whether data can or will be released. That may not prevent a rouge government employee like Booth from violating the law, but it provides clear notice to the FAA – and evidence for the courts – that the data is not to be released.

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ARSA on the Hill

Workforce Is Priority for Proposed Aviation Advancement Center

Senators Jim Inhofe (R-Okla.) and Tammy Duckworth (D-Ill.), longtime champions for U.S. aerospace jobs, are leading a new effort to strengthen America’s 21^st century aviation workforce.

On May 21, the senators introduced a bill to create a National Center for the Advancement of Aviation (NCAA), which would “serve as a national, independent forum to facilitate collaboration and cooperation between all sectors of aviation and aerospace stakeholders and related partners, with a particular focus on aviation and aerospace workforce development.”

The legislation (S. 1752) directs the NCAA to:

• Promote development of a well-qualified, well-trained civil and military aviation and aerospace workforce.
• Research and develop new aviation and aerospace training materials and products.
• Coordinate the dissemination of grants for the development of aviation and aerospace oriented high school STEM education curriculum.
• Facilitate collaboration between institutions of higher education or other research institutions engaged in aviation, aerospace or related research or technical development.

Senators Cindy Hyde-Smith (R-Miss.), Marco Rubio (R-Fl.) and Ron Wyden (D-Ore.) joined Inhofe and Duckworth on the bill as original cosponsors. Rep. Andre Carson (D-Ind.) introduced parallel House legislation (H.R. 3482) on May 26 with nine cosponsors, including House Aviation Subcommittee Chairman Rick Larsen (D-Wash.).

The legislation has been endorsed by ARSA, as well as member companies AAR, HAECO Americas, StandardAero, ST Engineering North America, STS Aviation Group, Triumph Airborne Structures and the Wencor Group, among others.

The strong industry and bipartisan support bode well for the legislation, which may be included in larger infrastructure package later this year. In the meantime, please use ARSA’s grassroots action site to send pre-prepared message to your elected representatives urging them to support the bill.  It’s quick and easy.  Just go to arsa.org/congress.

Congress Eyes Urban Air Mobility Opportunities

As interest in electric fixed wing and vertical take-off and landing aircraft (eVTOL) grows, Congress is considering legislation aimed at supporting the sector’s development.

On May 12, the Senate Committee on Commerce, Science and Transportation approved the Advanced Air Mobility Coordination and Leadership Act (S. 516), introduced by Senators Jerry Moran (R-Kan.) and Krysten Sinema (D-Ariz.) on March 1. The legislation would establish an Advanced Air Mobility (AAM) interagency working group to further U.S. leadership, amplify economic and job creation opportunities, advance environmental sustainability and new technologies and support emergency preparedness and competitiveness. The working group would be overseen by the Department of Transportation and made up of representatives from eight other agencies and departments (including Commerce, Defense and Homeland Security). The legislation also directs coordination with industry stakeholders, including maintenance providers.

In addition to developing a report on the current state of AAM, the working group would be tasked with developing a national strategy detailing steps the federal government can take to support the industry’s development and how various parts of the federal government can coordinate AAM-related activities.

Parallel AAM legislation (H.R. 1339) was introduced in the House by Rep. Sharice Davids (D-Ks.) and House Aviation Subcommittee Ranking Member Garret Graves (D-La.) in February but has not been acted on by the subcommittee.

In related news, on May 10, ARSA joined with allied organizations in a letter to Congress urging that any infrastructure package include grant money to help cities and counties evaluate and support the growth of AAM in their communities.

What impact or opportunities do you perceive for your company with the emergence of electric aircraft? Go to our Ask ARSA First! portal and let us know.

Now is the Time

With pandemic restrictions lifting and more Americans engaging in face-to-face meetings, it’s time to host visits by elected officials to your facilities.

Congress has a major impact on the maintenance industry. The association and its members have cultivated allies on the Hill who have supported workforce and regulatory initiatives, as well as legislation to direct economic relief to the industry. To reinforce those relationships and build new ones can be done by hosting a lawmaker visit to your company.

The meetings (which generally last less than an hour) are an opportunity to discuss company and policy issues that impact markets and costs of doing business. They are also a great way to give lawmakers hands-on perspectives about what your company does and how it fits into the local, national, and global economies.

Members of Congress and staffers are always anxious to get “up close and personal” with constituents and visiting a thriving local company and meeting its employees achieves that goal.

ARSA’s team is well versed in setting up facility visits. In addition to connecting members with congressional offices, the association will provide an agenda for the meeting, talking points and briefing materials to ensure the visit a success.

For more information, just Ask ARSA.

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Training

Make ARSA Training Work for 2021

ARSA’s online training program represents its most-valuable benefit to the aviation industry: knowledge gained through training and experience. The association’s team has turned its decades of work on behalf of aviation maintenance into more than 80 hours of on-demand content.

While sessions are available for registration at any time – ARSA member discounts available – companies can also incorporate the association’s training into their regular programs:

(1) Subscription. Make up-front, bulk purchases of training hours. The details of each subscription can be customized, including focus on specific subject areas (e.g., human factors) or options for specially-priced session access after the initial hours have been used.

(2) “Championing” a session. Guarantee a certain number of attendees for training in a particular topic that will also be made available for general registration. Variations include open registration for a live session (i.e., company personnel participate at the same time as general registrants) or a company-specific live event for which a recorded version (not including any company-specific information) is made available for on-demand registration.

(3) Tailored training. Contract ARSA’s management firm Obadal, Filler, MacLeod & Klein, P.L.C. to produce or modify training specific to your organization. The team can then re-record it (or offer it as a separate live session) for ARSA’s training program. Tailored programs are priced differently from ARSA’s hourly rate and are administered by OFM&K, which allows for a client engagement and related attorney-client privilege for all discussion.

Click here to go directly to the training platform (operated by ARSA’s management firm) and begin reviewing available sessions.

For more information about ARSA’s training program, review the menus below. If you have questions or would like to learn more about ways to integrate ARSA training into your own program, contact Vice President of Operations Brett Levanto (brett.levanto@arsa.org).

The association’s training program is provided through Obadal, Filler, MacLeod & Klein, P.L.C., the firm that manages ARSA. To go directly to OFM&K’s online training portal, visit potomaclaw.inreachce.com. To learn more about the association’s training program and see course availability, visit arsa.org/training.

What training do you need? Contact ARSA to let the association know and help get it developed.

Careers in Crisis

While some believe the international business impacts of the pandemic – including furloughs and other workforce reductions – staved off a long-brewing human capital crisis, the opposite is true. Learn about how businesses can continue to focus on their people regardless of forces beyond their control.

Session Recorded on March 11 of ARSA’s 2021 Annual Conference.

Kyle Kaiser, President, Veteran Internships Providing Employment Readiness (VIPER)
April Keister, Quality Engineer, Barnes Aerospace
Brett Levanto, Vice President of Operations, ARSA (Moderator)

The discussion can be accessed via the online training platform utilized by ARSA.

Click here to access the session.

Click here to review all content available from the Conference.

Registration for an ARSA-provided training session includes:

• Unlimited access for 90 days to the recording made available after the live session is complete.
• A copy of the presentation and all reference material with links to relevant resources and citations.
• A certificate upon completion of the class, as well as any test material.

The association’s training program is provided through Obadal, Filler, MacLeod & Klein, P.L.C., the firm that manages ARSA. To go directly to OFM&K’s online training portal, visit PotomacLaw.inreachce.com. To learn more about the association’s training program and see course availability, visit arsa.org/training.

Conversations with the Regulators (Four Hours)

The “Opening Salvo” is the centerpiece of ARSA’s Annual Repair Symposium, which is now part of the association’s complete Annual Conference Week hosted each March. During the morning-long discussion, international agencies provide updates on the regulations, policies and procedures governing the maintenance industry.

Session Recorded on March 11 during ARSA’s 2021 Annual Conference.

Rick Domingo, Executive Director, Flight Standards Service, FAA
Dan Elgas, Manager, Strategic Policy Branch, FAA
Thomas Mickler, Washington Representative, EASA
Karl Specht, Principal Coordinator, Organisation Approvals, EASA
David Malins, Head of Airworthiness, UK CAA
Neil Williams, Safety Policy Manager, Operations, UK CAA
Jeff Phipps, Chief, Operational Airworthiness, Standards Branch, Transport Canada Civil Aviation
João Souza Dias Garcia, Manager, Operations Regulations and Support, ANAC Brazil
Li Heping, Continuous Airworthiness & Maintenance Division, Flight Standards Department, CAAC
Xue Shijun, Deputy Director General, Flight Standards Department, CAAC
Marshall S. Filler, Managing Director & General Counsel, ARSA (Moderator)

The discussion can be accessed via the online training platform utilized by ARSA.

Click here to access the session.

Click here to review all content available from the Conference.

Registration for an ARSA-provided training session includes:

• Unlimited access for 90 days to the recording made available after the live session is complete.
• A copy of the presentation and all reference material with links to relevant resources and citations.
• A certificate upon completion of the class, as well as any test material.

The association’s training program is provided through Obadal, Filler, MacLeod & Klein, P.L.C., the firm that manages ARSA. To go directly to OFM&K’s online training portal, visit PotomacLaw.inreachce.com. To learn more about the association’s training program and see course availability, visit arsa.org/training.

Regulatory Compliance Training

Test your knowledge of 14 CFR §§ 11.27 & 29, Information gathering beyond NPRMs.

Click here to download the training sheet.

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Membership

Email Safety

Protecting Your Inbox (and ARSA’s Reputation)

Multiple ARSA members have reported receipt of solicitation emails offering sales of “ARSA Leads” or “Delegate Lists” including association contacts. ARSA has no relationship with the senders of these messages, has not provided contact lists of any kind to “lead sales” organizations and would never knowingly allow an outside party to solicit its members without clearly explaining the organization’s relationship to the association.

What to do…

If you receive this or any other outreach claiming an ARSA connection and you are unsure about its validity:

(1) Review the outline of ARSA’s communications practices below to see how the message could fit.
(2) Contact ARSA Vice President of Operations Brett Levanto for further clarification or to report a fraudulent message.
(3) If/when you are sure the message is fraudulent, submit a report to reportfraud.ftc.gov or an equivalent government entity if you are located outside the United States.

For more information about protecting yourself from email-based scams, visit the U.S. Federal Trade Commission website.

ARSA Newsletters and Outreach

Member contacts should expect to regularly receive the following general communications from the association:

Weekly: The Dispatch newsletter is distributed every Wednesday (open subscription, member contacts are automatically signed up to receive).
Monthly: The hotline newsletter is distributed the first week of each month (members only).
Various:  Member alerts are distributed as necessary – the association sends them only regarding specific events, activities or updates demanding specific attention.
Membership Term Dependent: Renewal reminders begin flowing out 90 days before the expiration of membership term.

In addition to these large scale distributions, ARSA team members will use their @arsa.org email addresses to coordinate directly with member contacts related to association business and industry matters.

Special Advertiser Distributions

From time to time, ARSA provides a mechanism for sponsors of its Dispatch and hotline newsletters to reach readers directly through sponsored “blast” emails. Allowing this advertising option gives companies a chance to directly show their support of the association and provide useful information and resources to readers. While receiving this message, ARSA subscribers and members should be assured that:

(1) The frequency of special “blast” messages is kept to a minimum. This maintains the special focus provided to advertisers sending the messages and prevents “overload” in readers’ inboxes.
(2) Advertisers are not provided direct access to newsletter subscription lists. Messages are constructed and distributed through ARSA’s partner Multiview, which oversees its periodicals.
(3) ARSA team members review and approve all messages prior to distribution.

For questions about ARSA’s advertising options, including ways to stand up for the association through your company’s support, contact Brett Levanto.

Advertising Solicitations

The only external entity that will contact member organizations on ARSA’s behalf is Multiview, which manages advertising in the association’s newsletters and on its website. Multiview’s sales team will always explain their relationship to ARSA – if you receive a message that does not, contact ARSA.

Spam Filters and Firewalls

It can sometimes be difficult for organizations like ARSA to get messages into your inbox. To ensure you have access to every newsletter, alert and update, ensure that the following domains are on your “safe list”:

@arsa.org
@potomac-law.com
@multibriefs.com

To learn more about ARSA’s communications efforts – including how to advertise – visit arsa.org/news-media. For assistance with technical issues, consult your organization’s IT department/assistant as necessary.

Quick Question – Emerging Tech & Inspector Skills

On May 13, the U.S. Government Accountability Office (GAO) released an assessment of FAA workforce planning (for full coverage, visit arsa.org/gao-workforce). In an appendix to the report, the GAO included a list and description of four key emerging technologies identified through its research.

ARSA’s position is that FAA (and industry) workforce development shouldn’t be responsive to specific technologies but instead include means for constant assessment of needed knowledge and skills. As part of that larger discussion, the association requests feedback about the specific areas highlighted by the GAO – and additions to the list – via this month’s “quick question”: 

If the embedded survey does not appear/load, open the survey independently by visiting: https://www.surveymonkey.com/r/qq-aviationtech.

Note: The survey below is in an embedded window and you may need to scroll down within the window to see/click the “Submit” button.

Click here to see what questions have been asked and answered…and keep a lookout for more.

For more information about this or any other question, contact Brett Levanto (brett.levanto@arsa.org).

Welcome & Welcome Back – New & Renewing Members

ARSA’s members give the association life – its work on behalf of the maintenance community depends on the commitment of these organizations. Here’s to the companies that joined or renewed in May:

New Members

Aero Brigham, LLC, R02
Business Jet Services, LTD. dba Business Jet Access, R02

Renewing Members

Aerospace Turbine Rotables, Inc. (Texas), R01, 2016
AeroKool Aviation Corporation, R04, 2017
Aviation Communication & Surveillance Systems, LLC, R02, 2002
Aviation Repair Resources, Inc. (ARR), R02, 2009
Aviation Safety Products, Inc., R01, 2013
Fargo Jet Center, R04, 2020
Honeywell International, Inc., Corp, 1996
Houston Aircraft Instruments, Inc., R01, 2002
L. J. Walch Co., Inc., R03, 1985
NAASCO Northeast Corporation, R02, 2002
Pacific Aero Tech, LLC, R03, 1994
Pennsylvania State University, EDU, 2016
Performance Repair Group, LLC, R02, 2013
Piedmont Propulsion Systems, LLC, R03, 2011
Quality Aviation Instruments, Inc. dba QAI Aerospace, R03, 2012
R.W. Raddatz, Inc., R03, 2004
Southwest Aerospace Technologies, LLC, R01, 2019
STS Aviation Group, Corp, 2020
Thales Avionics, Inc., R04, 2006
Triumph Airborne Structures, LLC, Corp, 2003

A Member Asked…

Q: Our repair station would like to apply for assistance from the Aviation Manufacturing Jobs Protection (AMJP) Program; how do I make sure we meet all the requirements?

For example, the Act requires reduction of revenues or personnel (because of layoffs or furloughs) in 2020 compared to 2019. Our revenues were way down last year, and we are slightly smaller than we were at the start of 2020.

We have finally seen an increase in work since March, so revenues are rising, and our current employees are not in immediate jeopardy. Does this recent uptick disqualify us from benefits? Is the program only for companies whose “problems” from last year continue?

A: The short answer is the years of focus are 2019 and 2020, not 2021; and, the evaluation is either employee or revenue related.

If you were part of the Department of Transportation webinar on May 21, you learned the agency is trying to fill in the gaps in the law. At this point, the best resources are the law itself and the initial Federal Register notice.

The law is very specific that, to be eligible, a company must (among other things) have “involuntarily furloughed or laid off at least 10 percent of its workforce in 2020 as compared to 2019 or has experienced at least a 15 percent decline in 2020 revenues as compared to 2019.” The Federal Register notice says applicants will be required to submit:

Details sufficient to demonstrate how the applicant meets the requirement to have ‘‘involuntarily furloughed or laid off at least 10 percent of its workforce in 2020 as compared to 2019 or has experienced at least a 15 percent decline in 2020 revenues as compared to 2019.’’ The applicant will be required to provide either aggregate numbers of personnel as of April 1, 2019 and April 1, 2020, or total operating revenue figures for the applicant’s fiscal years ending 2019 and 2020.

Based on this language, the 2021 situation isn’t relevant. The best way to position your company at this point is to follow the recommendations on the DOT website so you’re ready to submit an application. According to the webinar, it’s going to be a while before the money starts flowing (the presenters were hopeful money would go out the door this fiscal year). Hopefully, business continues to pick up, but that fact should not be a disqualifying event.

Make ARSA’s Voice Your Own: Advertise

ARSA has a menu of advertising opportunities for arsa.org, the hotline and the ARSA Dispatch. Take advantage of these great opportunities today to showcase your company, a new product or event. For more information go to arsa.org/advertise.

Stand Up for ARSA

In order to provide world-class resources for its members, the association depends on the commitment of the aviation community. By sponsoring events and activities, supporters can help ARSA’s work on behalf of repair stations to endure.

Need a place to start? For information about opportunities, contact Vice President of Operations Brett Levanto (brett.levanto@arsa.org).

Return to Top of Page

Resources

ARSA strives to provide resources to educate the general public about the work of the association’s member organizations; should you need to provide a quick reference or introductory overview to the global MRO industry, please utilize AVMRO.ARSA.org.

Anti-Viral Measures

For the use of its members and the larger aviation community, ARSA is maintaining this page as a resource for pandemic-related updates on policy initiatives and business needs. It is the association’s central point of communication on the topic

Resources for Dealing with the Government

As a repair station, dealing with the government, particularly the Federal Aviation Administration (FAA) is inevitable. Building a good relationship with government officials in good times will help keep the bad times at bay.

Industry News Roundup

ARSA monitors media coverage on aviation maintenance to spread the word about the valuable role repair stations play globally by providing jobs and economic opportunities and in civic engagement. These are some of this month’s top stories highlighting the industry’s contributions. You can explore these stories through ARSA’s Dispatch news portal.

Industry Calendar

the hotline is the monthly publication of the Aeronautical Repair Station Association (ARSA), the not-for-profit international trade association for certificated repair stations. It is for the exclusive use of ARSA members and federal employees on the ARSA mailing list. For a membership application, please call 703.739.9543 or visit arsa.org/membership/join. For information about previous editions, submit a request through arsa.org/contact. This material is provided for educational and informational purposes only. It does not constitute legal, consulting, tax or any other type of professional advice. Law, regulations, guidance and government policies change frequently. While ARSA updates this material, we do not guarantee its accuracy. In addition, the application of this material to a particular situation is always dependent on the facts and circumstances involved. The use of this material is therefore at your own risk. All content in the hotline, except where indicated otherwise, is the property of ARSA. This content may not be reproduced, distributed or displayed, nor may derivatives or presentations be created from it in whole or in part, in any manner without the prior written consent of ARSA. ARSA grants its members a non-exclusive license to reproduce the content of the hotline. Employees of member organizations are the only parties authorized to receive a duplicate of the hotline. ARSA reserves all remaining rights and will use any means necessary to protect its intellectual property.

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